Corbalis v. Comm'r
United States Tax Court
Petitioners seek judicial review of Letters 3477 denying their claim for interest suspension under I.R.C. sec. 6404(g) and stating that the determinations are not subject to judicial review under I.R.C. sec. 6404(h). Respondent has moved to dismiss for lack of jurisdiction.
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Petitioners seek judicial review of Letters 3477 denying their claim for interest suspension under I.R.C. sec. 6404(g) and stating that the determinations are not subject to judicial review under I.R.C. sec. 6404(h). Respondent has moved to dismiss for lack of jurisdiction. Held: The Court has jurisdiction under I.R.C. sec. 6404(h) to review denials of interest suspension under I.R.C. sec. 6404(g). Held, further, the Letters 3477 were final determinations for purposes of I.R.C. sec. 6404(h) even though petitioners' concurrent claims for abatement under I.R.C. sec. 6404(e) were still pending.
1Opinion of the Court
CHARLES M. CORBALIS AND LINDA J. CORBALIS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Corbalis v. Comm'r
Docket No. 8220-13.
United States Tax Court
142 T.C. 46; 2014 U.S. Tax Ct. LEXIS 2; 142 T.C. No. 2;
January 27, 2014, Filed
An order denying respondent's motion to dismiss will be issued.
Petitioners seek judicial review of Letters 3477 denying their claim for interest suspension under I.R.C. sec. 6404(g) and stating that the determinations are not subject to judicial review under I.R.C. sec. 6404(h). Respondent has moved to dismiss for lack of jurisdiction.
Held: The Court has…
2Cases cited29 opinions
- Citizens to Preserve Overton Park, Inc. v. VolpeSupreme Court of the United States · 1971
- Califano v. SandersSupreme Court of the United States · 1977
- Commissioner v. SchleierSupreme Court of the United States · 1995
- Woodral v. CommissionerUnited States Tax Court · 1999
- Hinck v. United StatesSupreme Court of the United States · 2007
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